Hazardous materials audits

Facilities Reviews There are many lands of facilities reviews that are useful in detec ting and preventing process safety problems. They include pre-start-up reviews (before the plant operates), new-plant reviews (the plant has started, but is stiU new), reviews of existing plants (safety, technology, and operations audits and reviews), management reviews, critical instrument reviews, and hazardous materials transportation reviews. 

The OSHA audit teams found program defieieneies in two related areas the development of task- and operation-speeifie hazard analyses and the eonduet of monitoring programs designed to eharaeterize employee exposures to hazardous materials. These defieieneies are dis-eussed in more detail below. 

Hazardous material (HAZMAT)-. Effective HMIS (hazardous material identification system) and MSDS (material safety data sheet) programs are both essential elements of a safety program The HMIS system identifies and labels substances that may pose some hazard to those who use them. The MSD sheets, provided by the suppliers of materials deemed to be hazardous, are kept on file to quickly identify all hazards and the appropriate responses in emergency situations. This mandated part of a safety program can be handed off to a subteam that ensures the MSDS database in updated and the HMIS labeling program is audited for compliance. 

To begin operations as an interstate carrier, or as an intrastate carrier transporting hazardous materials, the company must file an MCS-150 with the FMCSA and receive a US DOT number. This nrunber, or registration, then allows the company to operate commercial vehicles in interstate commerce. Part of this process will involve a new-entrant safety audit. A new-entrant safety audit involves a safety investigator reviewing the company s compliance with the safety regulations sometime dming the first 18 months of operation. 

Audit and report, on a regular basis, unsafe conditions and practices, hazardous materials, and environmental factors within the organization. 

Safety Compliance Review Self-Audit — Hazardous Materials Training... 

Safety Comphance Review Self-Audit — Hazardous Materials and Record Retention Taking What You Learned Questions for Management... 

Similar to the previous new entrant requirements, the safety audit will consist of a review of the new entrant s safety management systems and a sample of required records to assess compliance with the Federal Motor Carrier Safety Regulations (FMCSRs), applicable Hazardous Materials Regulations (HMR), and related recordkeeping requirements... 

Safety health and environmental audit (SHE) of constructed plant before introducing hazardous materials... 

Experience has shown that when OSHA conducts a compliance audit of a plant, facility, and/or other workplace, the auditors routinely seek out and document any container containing hazardous materials. When they find one (and more), they usually write down the brand name of the product and later ask to see an MSDS for each product found. Again, based on personal experience, it is at this point in the audit process that the property owner or manager gets into trouble with OSHA compliance (if not already there). We have found that it is not unusual for the in-house facility compliance manager to forget the Hazard Communication Standard requirement for the facility to produce and maintain a current inventory of all chemical products within the workplace. 

Now you can reconsider the material balance equations by adding those additional factors identified in the previous step. If necessary, estimates of unaccountable losses will have to be calculated. Note that, in the case of a relatively simple manufacturing plant, preparation of a preliminary material-balance system and its refinement (Steps 14 and 15) can usefully be combined. For more-complex P2 assessments, however, two separate steps are likely to be more appropriate. An important rule to remember is that the inputs should ideally equal the outputs - but in practice this will rarely be the case. Some judgment will be required to determine what level of accuracy is acceptable, and we should have an idea as to what the unlikely sources of errors are (e.g., evaporative losses from outside holding ponds may be a materials loss we cannot accurately account for). In the case of high concentrations of hazardous wastes, accurate measurements are needed to develop cost-effective waste-reduction options. It is possible that the material balance for a number of unit operations will need to be repeated. Again, continue to review, refine, and, where necessary, expand your database. The compilation of accurate and comprehensive data is essential for a successful P2 audit and subsequent waste-reduction action plan. Remember - you can t reduce what you don t know is therel... 

Trade secrets may be used in developing the information for the process hazard analysis emergency planning and responses, and compliance audits. Materials that are developed involving trade secrets may be treated as proprietary and may require signed statements for tl protection. 

This safety audit is used for identifying inputs and material flows, processes and intermediates, and final products - but with special attention paid to human-material/process/equipment interactions that could result in (a) sudden and accidental releases/spills, (b) mechanical failure-based injuries, and (c) physical injuries - cuts, abrasions, and so on, as well as ergonomic hazards. Additional sources of adverse effects/safety problem areas are records/ knowledge of in-plant accidents/near misses, equipment failures, customer complaints, inadequate secondary prevention/safety procedures and equipment (including components that can be rendered non-operable upon unanticipated events), and inadequacies in suppliers of material and equipment or maintenance services. 

Quality control in the upstream supply chain is part of our supplier approval system and regular supplier auditing. The applied control systems are based, as within our own factory premises on the HACCP systems (Hazard Analysis on Critical Control Points). These quality control systems have been elaborated for each individual raw material. It is our objective to source our raw materials as far as possible from approved suppliers these are suppliers who are able to guarantee the qualities we require. 

The next example is of a Pre-Startup Review or a Process Hazards Audit held on a piece of purchased processing equipment, a Haake Rheocord Torque Rheometer and Laboratory Twin-screw Extruder. The organization responsible for this extruder has a standard checklist of eleven pages of items to be considered by the technical person or persons in charge of the equipment or process, before the review is held. Copies of the completed checklist are then sent to each committee member before the meeting for review. Generally, in a review of this type, the group will convene at the location of the equipment rather than in a conference room to go over the material provided. In this case, the committee consisted of ... 

There is no hazardous waste generated when lithium batteries are recycled at Toxco Inc. There is no municipal sewer system in the processing area and air emissions are collected via a direct-capture-system over each of the reaction areas. These fumes are processed through three air filters coimected in series the first is a wet bed fume scrubber which removes particulate material, the second is a traveling bed filter to further remove particulate material, and the third treats the emissions chemically. Each year Toxco is required to hire an outside environmental audit firm to test the emissions for conformance with their permit. The 1999 results are presented in Table 1. As one can see the emissions are quite minor in comparison to the allowable limits. 

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